Depends...
Were they "Denied" for the original loan and this is a new loan completely, or is this a true counter offer...
If it is a counter offer, then your Reg B "clock" is satisfied...
You can and should redisclose the early TIL.
But you have to be careful about the GFE because a counter offer isn't a CoC all by itself (I think, I am remembering that correctly). So you may not be able to redisclose the GFE citing a change of circumstance since YOU initiated the changes, not the borrower...
If the GFE is substantially wrong given the new product, then IMO your best bet would be deny the original loan application outright and have the customer reapply for the in-house product... This would reset all your disclosures and timeframes...
Cheers!
_________________________
In life, there is a lot less that could get better and a lot more that could get worse.
MBA Fin/MBS HR
My views only!